IPI No. 15-35-SB-J, February 23, 2016
RE: VERIFIED COMPLAINT DATED JULY 13, 2015 OF ALFONSO V. UMALI, JR., Complainant, vs. HON. JOSE R. HERNANDEZ, ASSOCIATE JUSTICE, SANDIGANBAYAN, Respondent.

FACTS

Complainant Alfonso V. Umali, Jr., then Provincial Administrator of Oriental Mindoro and an accused in Criminal Case No. 23624 for violation of the Anti-Graft and Corrupt Practices Act before the Sandiganbayan, filed an administrative complaint against Sandiganbayan Associate Justice Jose R. Hernandez for grave misconduct and gross ignorance of the law. The Sandiganbayan (Fourth Division), in a decision penned by Justice Hernandez dated April 20, 2015, convicted Umali and two others. Umali filed a motion for reconsideration and a motion for voluntary inhibition of Justice Hernandez, which were denied. In his complaint-affidavit, Umali alleged that before the April 20, 2015 decision, a certain Ruel Ricafort (cousin of Justice Hernandez’s wife) approached his “camp” and relayed a demand for P15 million in exchange for his acquittal, which he refused. Umali also claimed Justice Hernandez showed manifest partiality by: (a) instructing the clerk of court not to allow a reply to the prosecution’s comment; (b) asking loaded questions and “lawyering” for the prosecution; and (c) making dismissive remarks to his counsel. Justice Hernandez, in his comment, countered that the allegations were bare and lacked specifics, noting Umali had no personal knowledge of the extortion attempt and failed to report it promptly or provide supporting affidavits.

ISSUE

Whether Justice Hernandez is administratively liable for grave misconduct and gross ignorance of the law based on the allegations of extortion and manifest partiality.

RULING

The Supreme Court DISMISSED the administrative complaint for lack of merit. The Court held that in administrative proceedings, the complainant bears the burden of proving allegations by substantial evidence. Umali failed to meet this burden:
1. On the alleged extortion attempt: Umali’s allegations were based on hearsay, as the information was merely “relayed” to him. He provided no specifics (e.g., time, place, identities of persons involved) and did not submit affidavits from witnesses or report the incident promptly. The hearsay evidence was uncorroborated, and the timing of the complaint—filed after conviction and denial of his motions—suggested it was motivated by the adverse outcome. The presumption of regularity in Justice Hernandez’s duties prevailed.
2. On manifest partiality: The records did not support Umali’s claims. The clerk of court’s statement that the court gave no instructions to allow a reply did not prove bias, as filing a reply is discretionary under Sandiganbayan rules. The denial of a reply alone does not constitute partiality. The other allegations of loaded questions and dismissive remarks were insufficient to prove bias, as judicial rulings and courtroom interactions, without more, do not establish partiality. The Court emphasized that disciplinary actions cannot be based on mere speculation or dissatisfaction with judicial decisions.